Russia-related General License 35 - Authorizing Transactions Involving Credit Rating and Auditing Services (May 8, 2022)

Date issued: May. 08 2022

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TURBOFAC Commentary (100 words)

Notes:

1) Compare FAQ # 1038. Compare also Russia-related General License 13. As implicit from FAQ # 1034, "credit rating or auditing services" are within the scope of the EO 14071 service prohibition as “accounting” services.

2) Query: are credit rating services with respect to a Russian entity bond service supplied "to" the issuer, even if the services are provided at the best of, and for the benefit, of others?

3) See General Note on E.O. 14071-Based Prohibitions on the Exportation of Certain Services to Persons Located in Russia (System Ed. Note) for comments on the relevant prohibitions in general.